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ATP decison sparks new review
HMRC are further reviewing the VAT treatment of fund management services to take account of the outcomes in PPG Holdings BV (C-26/12) and ATP Pension Services (C-464/12).
As a result of the Court of Justice of the European Union (CJEU) decision in PPG, employers have been able to deduct some VAT incurred in relation to pension fund management, which the Revenue had previously considered not deductible.
Details were contained in Revenue & Customs Brief (RCB) 6/14.
The tax department has now published RCB 22/14 to update its position after the CJEU’s ruling in ATP and to extend the transitional period announced in RCB 6/14. Guidance on how the two judgments are to be implemented is expected in the autumn.
New claims – for input tax following PPG or in relation to output tax in response to ATP – should be made by email.
